### Red Fork Solutions 14690 Country Lane Kingfisher, OK 73750

September 18, 2015

U.S. Department of Transportation Docket Management System 1200 New Jersey Ave, SE Washington, DC 20590

To Whom It May Concern:

Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 and 14 CFR Part 11, Steve Neuman, president of Red Fork Solutions, hereby applies for an exemption from the Federal Aviation Regulations (FARs) identified in this document, to allow commercial operations of small unmanned aerial system (sUAS) in airspace regulated by the Federal Aviation Administration (FAA).

Public Interest



### Red Fork Solutions (RFS) respectfully requests an exemption from several provisions of Title 14 of the CFR to permit the use of sUAS to assist in the evaluation of infrastructure and operations of our clients in the oil/gas, utility, cellular, agriculture industries and to provide aerial photography/video for real estate clients and those in the television and film industry. This request is motivated by the desire to maximize safety in infrastructure and operations as well as providing valuable cost savings to the companies. The use of a sUAS reduces the need for conventional aircraft in situations where the safety of the public is in question or it is simply not practical.

RFS is located in a rural community near Oklahoma City, Oklahoma where there is considerable oil/gas exploration, wind energy projects and utility line operations. Being in rural western Oklahoma, agriculture is the primary industry giving RFS an opportunity to offer precision agricultural inspections to local farmers and agri business. The close proximity to Oklahoma City further expands the opportunities for RFS to provide aerial video and photography to a wide range of customers in the real estate, construction and film industries. The president of RFS has over 1300 hours of total time and maintains a commercial license with the FAA to include an instrument rating with a Class II medical for single engine land operations.
RFS operations under the exemption will be subject to strict operating requirements and conditions to ensure an equivalent level of safety to currently authorized operations using manned aircraft and under conditions as may be modified by the FAA as required by Section 333.2.RFS missions will be conducted under VFR conditions at a low altitude in airspace that

is permitted in accordance with the approved Certificate of Authorization (COA). RFS will operate sUASs with pilots who are current and qualified with the FAA and who possess at least a Class III airmen's medical certificate. Missions which occur inside controlled airspace (other than class G) will be coordinated with the controlling air traffic control (ATC) in advance of the mission.

Drone Capabilities and Public Safety

The sUAS which RFS will be operating is the DJI Inspire 1. The inherent safety features, sophistication, programmability, GPS navigation, return home capability, airport vicinity no-fly feature and restricted altitude feature, as well as differentiating radio frequency (rf) for aircraft controller/receiver and for the camera make this sUAS particularly safe for the purposes of this request for exemption. The sUAS weighs approximately 6 Ibs, has a maxium speed of 43 knots, designed to be operated in 20 knot winds with an approximate battery run-time of 20 minutes.

Following a pre-flight systems check by the pilot in command (PIC), the sUAS will only be operated within visual line-of-sight (VLOS) by the (PIC) and/or visual observer unaided by any device other than corrective lenses during daytime, visual meteorological conditions (VMC). AII personnel not directly involved with the sUAS mission will be removed from the immediate area of intended operation (A10). The visual observer will ensure the public does not reenter the A10. The PIC will ensure that all missions remain at or below 400 feet above ground level (AGL), do not exceed 30 knots and are terminated with adequate power to provide for safe landing. The PIC will also program the sUAS to a maximum altitude that does not exceed the 400 foot AGL maximum as prescribed by the FAA.

Given the numerous exemptions previously granted by the FAA for the DJI Inspire 1, RFS will assume the FAA is familiar with the operational characteristics and will avoid redundancy in the process and not attach the manufacturer's data which is publicly available through the manufacturer's website.

Drone Preflight, Maintenance and Safety of Flight

In order to promote the best interests in protecting persons and public property, a sUAS checklist has been created mirroring the manufactures recommended operating procedures. Prior to each flight, the PIC must execute the pre-flight checklist in accordance with the sUAS user manual and operational documents.Red Fork Solutions sUAS Preflight Checklist

• Review airspace designation and obstacle/hazards in the area of intended operation (A10) • Obtain appropriate weather briefing for time and location of mission • Review take off/landing (TOL) location and determine alternative location if available • Place cones and/or placards in the area to designate the TOL area • Assemble drone as necessary for safe flight • Conduct manufactures pre-flight assessment of sUAS • Ensure camera and gimbal assembly are operational and functioning as normal • Initialize drone system, battery packs an camera/assembly • Verify transmitter battery status is at 50% or greater • Verify sUAS battery status is at 75% or greater • Verify visual device battery status is at 50% or greater • Conduct sUAS calibration and GPS satellite acquisition • Verify live video feed
• Set GPS return home location • Conduct motor run-up to verify they are functioning as normal

RF Spectrum and FCC Compliance

The Inspire 1's 2.4 ghz transmitter/controller/receiver rF for managing flight with a 5.8 ghz rf transmitter/receiver for video/photography functions eliminates the rf conflict. The sUAS system complies with all applicable FCC regulations.

PIC Qualifications and Responsibilities

• The PIC shall have at a minimum a private pilot certificate, current class III medical airman certificate and current biennial flight review. • 25 hours of total time as a sUAS pilot and 3 take offs and landings in the preceding 90 days. • The PIC will have the final authority to terminate or cancel a mission if the appropriate safety margins and conditions are not favorable for a safe flight.

sUAS Operations and Assurance of Public Safety

The purpose of the sUAS missions conducted by RFS will be to obtain video and still photography images of industrial facilities, oil/gas/electrical transmission lines, agricultural locations, real estate properties and locations for cinematography. The information obtained through the imagery will help engineers, inspectors, agronomist,

### and real estate investors perform virtual assessments in an efficient, safe and timely

manner. The video and still photography for film will provide an extremely affordable solution to getting aerial images that were previously obtained by using manned aircraft costing thousands of dollars. The use of a sUAS will reduce the need for manned aircraft operations to conduct those types of assessments while adding a level of safety over populated areas.
• The sUAS will weigh less than 55 pounds. • Flights will be operated within line of sight of the PIC and/or visual observer. • Flight time will be limited to the amount of time the sUAS can be flown and still maintain a reserve battery power of no less than 25%. • Flights will be operated at an altitude of no more than 400 foot AGL. • Flights will be operated at a lateral distance of at least 100 feet from any inhabited structures, buildings, vehicles, vessels and people not associated with the operation. • Minimum crew for each mission will consist of the sUAS PIC and a visual observer (VO). Additional personnel may consist of a camera operator. AII personnel associated with the mission must be able to communicate audibly without aid of radios. • The sUAS PIC will be an FAA licensed airman with at least a private pilot's license, third class medical and a current biennial flight review in an aircraft in which the PIC is rated. • The sUAS will only operate within a confined sterile area. • Prior to the mission, the PIC will obtain all available information about the location and weather to ensure a safe mission. • Prior to the mission, the PIC will conduct a pre-flight safety briefing to all personnel associated with the mission. • AII applicable manufacturer's checklist and RFS preflight checklist will be adhered to prior to each mission. • The sUAS will be maintained in compliance with the manufacturer's guidelines. • In the event of an accident involving an RFS sUAS, the PIC will cease operations and report the accident to the NTSB and AFS-80. • AII required permissions and permits will be obtained from territorial, state, county or local jurisdictions. RFS will notify public safety officials in those jurisdictions to avoid confusion and to provide transparent, legal missions. • In compliance with the approved waiver, RFS will submit a written "Plan of Activities" to the local Flight Standards District Office (FSDO) having jurisdiction over the area of proposed filming three days in advance of the mission during film or television productions. • The PIC will ensure the "return home" function is activated in the case of lost communication with the sUAS. • AII missions will cease when communication has been lost between the PIC and VO. • Individual privacy will not be violated by RFS through the use of a sUAS.Request for Exemptions

14 CFR 91.103: Preflight Action

RFS requests exemption from the preflight action requirements of 14 CFR 91.103 that prescribes the preflight actions under which an aircraft may operate:

Each PIC shall, before beginning a flight, become familiar with all available information concerning that flight.

RFS will not operate the sUAS under IFR conditions or when the ceilings are below 1000 feet and the visibility is below 3 statute miles. The Inspire 1 does not have a published approved airplane or rotorcraft flight manual containing takeoff and landing distance data. RFS will ensure the weather will be adequate to complete the mission in VFR conditions.

14 CFR 91.113: Right-of-Way Rules

RFS requests an exemption from 14 CFR 91.113 Right-of-Way rules, requiring vigilance by each person operating an aircraft so as to see and avoid other aircraft. When a rule of this section gives another aircraft the right-of-way, the pilot shall give way to that aircraft and may not pass over, under, or ahead of it unless well clear.

RFS's operation of the Inspire 1 does not allow compliance with this rule as the Inspire 1 is an unmanned aircraft. RFS will follow the previously stated sUAS operations and Assurance to Public Safety. The PIC will cease operations when another aircraft enters the sUAS A10 and will not resume the mission until the threat is clear.

14 CFR 91.119 Minimum Safe Altitudes

RFS requests an exemption from the minimum safe altitude requirements of 14 CFR 91.119 that prescribes the minimum safe altitudes under which aircraft may operate.

As previously described, RFS sUAS missions will be at or below 400 feet AGL and maintain a lateral distance of 100 feet from inhabited buildings, vehicles and vessels and from people not associated with the mission. 91.119(d) allows for a helicopter to operate at less than the minimum altitudes when it can be operated "without hazard to persons or property on the surface," provided that "each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA."

RFS's operation of the Inspire 1 quad copter sUAS would be similar to operations of a manned helicopter in the maneuverability and ability to maintain position from structures and/or people. The minimal weight of the Inspire 1 and lack of flammable fuel drastically reduces the risks that currently exist with conventional aircraft. RFS advanced notice to property owners and participants will further ensure the sUAS can be safely operated at lower altitudes.14 CFR 91.121 Altimeter Settings

RFS requests an exemption from 14 CFR 91.121, which requires a person operating an aircraft to maintain cruising altitude or flight level by reference to an altimeter that is set to the elevation of the departure airport or barometric pressure. An exemption is required because the Inspire 1 sUAS does not have a barometric altimeter, but rather a GPS altitude read out.

The PIC will confirm the local altitude at the AIO and compare with the GPS altitude to ensure the equivalent level of safety.

14 CFR 91.151 (a) Fuel Requirements for Flight in VFR Conditions

RFS requests exemption from 14 CFR 91.151(a) fuel requirements for flight in VFR conditions. The typical sUAS cannot meet the minimum fuel requirements for daytime VFR conditions. The battery powering the Inspire 1 provides approximately 20 minutes of powered flight before landing procedures are initiated. Given this limited amount oftime, flight operations in the A10 are predetermined to maximize the amount of time onstation while allowing a safety margin based on a reserve amount of battery power needed for safe landing. Operation of the sUAS with less than 30 minutes of reserve fuel does not include the type of risks that Section 91.151(a) was intended to alleviate given the size and speed of the small UAS, and the proximity of the flight operation to the landing zone. RFS will not conduct sUAS flights at night.

14 CFR 91.405(a), 91.407(a)(1), 91.409(a)(2), 91.417(a) and (b): Maintenance Inspections

RFS requests an exemption from the maintenance inspection requirements contained in the above mentioned regulations. These regulations specify maintenance and inspection standards in reference to 14 CFR Part 43. 14 CFR 91.405(a) stating that each owner or operator of an aircraft "shall have the aircraft inspected as prescribed in subpart E of this part and shall between required inspections ... have discrepancies repaired as prescribed in Part 43 of this chapter." An exemption to those regulations is needed because Part 43 and these sections only apply to aircraft with an airworthiness certificate, which the sUAS will not have.

RFS will achieve a similar level of safety by following the Inspire 1 manufactures maintenance and inspection recommendations. The PIC will ensure the sUAS is safe to operate during the pre-flight inspection and will log any necessary repairs. If mechanical issues arise during flight, the sUAS's size and carrying capacity and the fact that flight operations will only take place in restricted areas for limited periods of time during daylight hours, creates less risk than that associated with conventional rotorcraft performing the same operation.If additional information is required, or if you have questions regarding this petition for

exemption, please contact the undersigned at:

Respectfully,

Steve Neuman President Red Fork Solutions, LLC 405/368-2333 sneuman@pidi.net